Circle Internet Group, Inc.

Director and Officer Trading Arrangements.

During the fiscal quarter ended September 30, 2025, the following Rule 10b5-1 trading arrangements were adopted, amended, or terminated by certain executive officers of the Company:

On August 14, 2025, Jeremy Allaire, our Co-Founder, Chairman, and Chief Executive Officer, terminated his previously reported trading plan adopted on June 4, 2025 (the “Previous Allaire Plan”). As of the termination of the Previous Allaire Plan, no shares of our Class A common stock had been sold under the plan. The adoption and subsequent termination of the Previous Allaire Plan each occurred during an open trading window and in accordance with the Company’s policies. On August 14, 2025, in connection with the Company’s follow-on public offering, Mr. Allaire entered into a new trading plan, intended to satisfy the conditions under Rule 10b5-1 of the Exchange Act, which reduced the number of shares subject to the plan relative to the Previous Allaire Plan. Mr. Allaire’s plan provides for the sale of up to 93,723 shares of Class A common stock through November 13, 2026, which includes (i)84,627 shares of Class A common stock held directly by Mr. Allaire (following the conversion of Class B common stock to Class A common stock immediately prior to the sales) and (ii) an aggregate of 9,096 shares of Class A common stock held through Spruce Trust, Oak Trust, Chestnut Trust, and Beech Trust, each an irrevocable non-grantor trust, of which Mr. Allaire’s legal counsel is the sole trustee and Mr. Allaire’s children are beneficiaries. The foregoing sales will be made in accordance with the prices and formulas set forth in the plan and such plan terminates on the earlier of the date all the shares under the plan are sold and November 13, 2026. The plan was adopted during an open trading window and includes a cooling off period consistent with SEC requirements.

On August 14, 2025, Jeremy Fox-Geen, our Chief Financial Officer, terminated his previously reported trading plan adopted on June 4, 2025 (the “Previous Fox-Geen Plan”). As of the termination of the Previous Fox-Geen Plan, no shares of our Class A common stock had been sold under the plan. The adoption and subsequent termination of the Previous Fox-Geen Plan each occurred during an open trading window and in accordance with the Company’s policies. On August 14, 2025, in connection with the Company’s follow-on public offering, Mr. Fox-Geen entered into a new trading plan, intended to satisfy the conditions under Rule 10b5-1 of the Exchange Act, which reduced the number of shares subject to the plan relative to the Previous Fox-Geen Plan. Mr. Fox-Geen’s plan provides for the sale of up to 153,124 shares of Class A common stock through May 15, 2026. The foregoing sales will be made in accordance with the prices and formulas set forth in the plan and such plan terminates on the earlier of the date all the shares under the plan are sold and May 15, 2026. The plan was adopted during an open trading window and includes a cooling off period consistent with SEC requirements.

On August 14, 2025, in connection with the Company’s follow-on public offering, Heath Tarbert, our President, amended his previously reported trading plan adopted on June 4, 2025. As of the time of such amendment, no shares of our Class A common stock had been sold under the plan. The adoption and subsequent amendment of his plan each occurred during an open trading window and in accordance with the Company’s policies, and the amended plan includes a cooling off period consistent with SEC requirements. Mr. Tarbert’s plan was amended to reduce the number of shares subject to the plan, and it is intended to satisfy the conditions under Rule 10b5-1 of the Exchange Act. Mr. Tarbert’s amended plan provides for the sale of up to 338,330 shares of Class A common stock through June 5, 2026. The foregoing sales will be made in accordance with the prices and formulas set forth in the plan and such plan terminates on the earlier of the date all the shares under the plan are sold and June 5, 2026.

On August 15, 2025, in connection with the Company’s follow-on public offering, Nikhil Chandhok, our Chief Product and Technology Officer, amended his previously reported trading plan adopted on June 4, 2025. As of the time of such amendment, no shares of our Class A common stock had been sold under the plan. The adoption and subsequent amendment of his plan each occurred during an open trading window and in accordance with the Company’s policies, and the amended plan includes a cooling off period consistent with SEC requirements. Mr. Chandhok’s plan was amended to reduce the number of shares subject to the plan, and it is intended to satisfy the conditions under Rule 10b5-1 of the Exchange Act. Mr. Chandhok’s amended plan provides for the sale of up to 70,000 shares of Class A common stock through June 5, 2026. The foregoing sales will be made in accordance with the prices and formulas set forth in the plan and such plan terminates on the earlier of the date all the shares under the plan are sold and June 5, 2026.

On August 15, 2025, Sean Neville, one of ourdirectors, adopted a trading plan intended to satisfy the conditions under Rule 10b5-1 of the Exchange Act. Mr. Neville’s plan is for the sale of up to 980,000 shares of Class A common stock (including shares issuable upon exercise of outstanding stock options) through June 5, 2026. The foregoing sales will be made in accordance with the prices and formulas set forth in the plan and such plan terminates on the earlier of the date all the shares under the plan are sold and June 5, 2026. The plan was adopted during an open trading window and includes a cooling off period consistent with SEC requirements.

Other than the foregoing, during the fiscal quarter ended September 30, 2025, no directors or other executive officers of the Company adopted, modified, or terminated any Rule 10b5-1 trading arrangements.